From: Stephen Ringlee [mailto:sringlee@q.com] 

Sent: Sunday, September 13, 2015 11:51 AM

To: EBSA, E-ORI - EBSA

Subject: RIN 1210-AB32

RE: Public Comments on Proposed DOL Fiduciary Standards for Brokers and Agents Providing 

Investment Advice

Dear Friends:

This proposed Rule is long overdue and has my complete support. I learned early in my career that 

abuses are rife among purported investment advisors and that voluntary industry self-regulation is not a 

sufficient corrective. I cite some examples:

1. As a young corporate treasurer, I was asked by an older lady in our accounting group to help her 

reconcile her 401K plan withholdings and investments. After navigating through the 

deliberately obscure statements, we found that the broker offering the plan not only was 

charging a seven percent commission on all individual investments but was steering participants 

exclusively into proprietary products with uniformly higher annual fees. None of this had been 

disclosed at the time our firm had engaged this broker and we swiftly terminated the 

relationship. The proposed Rulemaking would have made the disclosures more prominent and 

limited the ability of the broker to limit participants to solely company-sold investment 

products. The rulemaking would also have altered the incentives of the broker by adding 

fiduciary obligations to his job description.

2. As a buyer of a pharmaceuticals firm, I found that the Individual Retirement Account and 401K 

programs offered by the firm had been heavily influenced by the investment manager such that 

most of the investments were in proprietary guaranteed investment contract offerings, not in 

the equity or bond market products also offered. The sales representatives who arranged for 

employee signups had heavily sold the “guaranteed” concept without disclosing either the high 

fees associated with them or the their inappropriateness for younger age groups. As it 

happened, these were very high margin products for the investment managers and their 

salespeople were compensated on commissions tied to the margins. The proposed Rulemaking 

would have improved the disclosures and limited the ability of the salespeople to steer plan 

participants into inappropriate investments with much higher profit margins without regard to 

any fiduciary obligations owed to the clients.

3. As a member of my community, I am continually encountering salespeople from various 

insurance firms who assert that they are “investment managers” who “act in the best interests 

of their customers” while at the same time limiting their offerings to proprietary products that 

tend to be much costlier and often less appropriate for the customer than broad market 

products available from many broker-dealers. The proposed Rulemaking would improve 

disclosures required of these agents and again encourage them to offer a broader range of more 

appropriate products to their customers based on a standard of fiduciary obligation.

This country is experiencing a retirement crisis with far too few savings to support far too many 

retirees. The proposed Rulemaking will at the very least begin to reduce the high fees charged to these 

savings and add a higher behavioral standard of “fiduciary reliance” for those offering retirement 

savings products. Those who cannot rise to this new, more stringent standard, should not be selling 

such products in the marketplace. Complaints of “over-regulation” and “higher costs” are vastly 
outweighed by the obligations to deal honestly and fairly with customers, obligations which heretofore 

have been lacking among many in the investment and insurance communities. It is time to change this 

by adopting these new Rules.

Kind regards,

Stephen Ringlee

2325 Storm St

Ames, IA 50014